ML20248H409
| ML20248H409 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/03/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20248H409 (10) | |
Text
From:
Kevin Kamps <kevin@beyondnuclear.org>
Sent:
Thursday, September 3, 2020 5:08 PM To:
Holtec-CISFEIS Resource
Subject:
[External_Sender] Beyond Nuclear's 19th set of public comments, re:
Docket ID NRC-2018-0052, re: NRC's Holtec/ELEA CISF DEIS
Dear NRC Staff,
This is my 19th set of public comments in this proceeding.
I submit these comments on behalf of our members and supporters, not only in New Mexico, near the targeted Holtec/ELEA Laguna Gatuna site, but across New Mexico, and the rest of the country, along road, rail, and waterway routes that would be used for high risk, highly radioactive waste shipments to Holtec's CISF, as well as to Yucca Mountain, Nevada, on Western Shoshone land -- bogusly assumed by Holtec, as well as NRC, to someday become a permanent disposal repository.
The following subject matter has gotten little to no attention in NRC's Holtec CISF DEIS, a far cry from NEPA's legally binding "hard look" requiremet.
Risks of Routine or Incident-Free Shipments Nonetheless Being Like Mobile X-ray Machines That Cant Be Turned Off, and Risks of Externally Contaminated Shipments Even routine or incident-free shipments of irradiated nuclear fuel carry health risks to workers and innocent passers by. This is because it would take so much radiation shielding to completely hold in the gamma and neutron radiation, being emitted by the highly radioactive waste, that the shipments would be too heavy to move economically. So NRC has compromised, and allows for or permits a certain amount of hazardous gamma and neutron radiation to stream out of the shipping container.
NRCs regulations allow for up to 10 millirem per hour (mR/hr) of gamma and/or neutron radiation to be emitted, about six feet (two meters, 6.6 feet) away from a shipping casks exterior surface. Thats about one to two chest X-rays worth of gamma and neutron radiation, per hour of exposure.
Since the radiation dissipates with the square root of the distance, this means that NRCs regulations allow for up to 200 mR/hr, at the surface of the casks exterior. Thats 20 to 40 chest X-rays worth of gamma and neutron radiation, per hour, which NRC allows to stream out, right at the casks surface.
NRC has done a cost-benefit analysis - the cost, to human health; the benefit, to the nuclear power industrys bottom line - and deemed these exposure levels acceptable or permissible.
(Permissible or acceptable should never be confused with safe or harmless - exposures to 200 mR/hr, or even 10 mR/hr, still carry health risks. After all, any level of exposure to
hazardous ionizing radiation, no matter how small the dose, has long been confirmed to cause cancer, and other maladies. For more information, see: >)
The humans actually harmed by these exposures to hazardous radioactivity - related to the industrys NRC-approved, unnecessary shipments, for example - might beg to differ! But of course, any negative health impacts associated with irradiated nuclear fuel shipments will not be closely tracked (or tracked at all) by NRC, or any other government agency for that matter. NRC and industry almost always downplay the health risks, and would almost certainly deny any connection between such exposures and negative health outcomes.
Six feet away could affect a person standing beside a train track, as the train goes by. Some real world examples of this situation include the Takoma Metro Station near Takoma Park, Maryland
- the Red Line Metro Station platform is right beside the CSX railway, which is targeted for trains to haul irradiated nuclear fuel from the Calvert Cliffs, MD and North Anna, VA nuclear power plants, such as bound for Holtec's proposed CISF in NM.
Although further than six feet away, residences located immediately adjacent to these same CSX rail lines in Tacoma, D.C. mean that those living there could well be exposed to gamma and neutron radiation, although at a lower dose rate (again, the dose rate decreases inversely with the square root of the distance). However, residents can be expected to be present in their homes a lot more often than commuters standing on a Metro platform - including during sleep hours, when trains carrying irradiated nuclear fuel could still go by. And of course, residents along these tracks, would also be commuters standing on the platform, leading to multiple exposures in their daily (and nightly) lives, for years or even decades on end, during a Holtec CISF shipping campaign.
Trains pausing next to commuter platforms or residences will prolong and exacerbate these hazardous and potentially injurious exposures. Paused trains - even ones carrying hazardous cargoes like highly radioactive waste - are commonplace in the U.S. Pauses can sometimes last a long time. Lead automobiles (the ones nearest the tracks) stuck by paused trains at railroad crossings could mean the occupants of those vehicles are exposed to prolonged dose of intense gamma and neutron radiation at such a close range distance. Even a rolling train car would emit a certain dose as it passed by, to lead car occupants stopped nearest the tracks.
Similar situations will arise across the U.S. Innocent passers by, whose daily lives bring them in close proximity to railways, waterways (barges), or roadways (heavy-haul trucks) that would be used to ship irradiated nuclear fuel, mean that ordinary people would be exposed to hazardous gamma and neutron radiation in some amount greater than zero - perhaps repeatedly, over the course of years, or even decades, during a Holtec CISF shipping campaign.
The 200 mR/hr acceptable dose rate at the surface of shipping casks would most likely impact workers - locomotive engineers, railway workers, inspectors, security guards, police, firefighters, emergency responders, etc.
However, when, in 2003, the Big Rock Point reactor pressure vessel (albeit so-called low level radioactive waste, it still serves as a cautionary tale) was shipped by heavy-haul truck into
Gaylord, Michigan to be loaded onto a train, for its shipment by rail to Barnwell, South Carolina, to be buried in a leaking ditch, neither the nuclear utility, Consumers Power, nor the NRC (nor any other federal or state agency), nor local law enforcement, created a security or safety or health perimeter around the shipping container. As if it were a parade, onlookers were allowed to simply approach the shipping container, walk right up to it, and even touch it. In fact, a parade would probably have had better health, safety, and security precautions in place! (See 2003 written entries, as well as a photo, about this and other incidents that occurred during this single shipment, posted online at: ). Holtec's CISF would involve up to 10,000 in-bound irradiated nuclear fuel shipments into the NM de facto permanent, surface storage, parking lot dump; and at least an equal number out, if the waste ever were to leave. (Holtec and NRC both erroneously simply assume Yucca Mountain, Nevada -- Western Shoshone land, by treaty right -- will be the permanent burial site.)
However, as expert witness Bob Alvarez has testified on behalf of CISF opponents in the NRC ASLB's Holtec proceeding, the 10,000 storage canisters could be subdivided into as many as 80,000 smaller diameter TADs (Transport, Aging, and Disposal canisters), for the out-bound shipment from the Holtec CISF in NM, to the falsely assumed dump-site at Yucca Mountain, Nevada. This would mean 80,000 canister shipments, each one "allowed" or "permitted" to emit 10mR/hr at a distance of 6.6 feet away, or up to 200 mR/hr at the canister overpack's surface.
Likewise, Bob Halstead, several years ago, was able to guide a camera crew deep into the heart of a rail yard, just off downtown Chicago, that would be used to temporarily store (albeit, temporarily could last for days) train cars holding irradiated nuclear fuel. Security was nowhere to be seen. (Halstead, then long serving as transport consultant to the State of Nevada Agency for Nuclear Projects, later long served as the agencys director, the position from which he recently retired.)
Similarly, Rick Hind of Greenpeace U.S.A. guided a Wall Street Journal reporter deep into the heart of underground train tunnels under Washington, D.C. The graffiti and art on the walls showed clearly that the tunnels are frequented by human beings. (Hind was showing the reporter how insecure such tunnels, even in the nations capital, are to potential security risks, even as hazardous train cargoes - including chlorine shipments, and perhaps someday soon, irradiated nuclear fuel - pass by.)
In these ways, that 200 mR/hr permissible dose rate could impact not only workers, but even members of the public -- such as graffiti artists in Washington, D.C.'s train tunnels!
In this sense, even routine or incident-free shipments of irradiated nuclear fuel can be considered as similar to mobile X-ray machines that cant be turned off, a phrase describing the concept first expressed by Lauren Olson, a supporter of NIRS (Nuclear Information and Resource Service).
To make matters worse, there have been large numbers of shipments, externally contaminated with radioactivity, making their actual dose rates much higher - and thus more hazardous - in serious violation of the already compromised permissible or acceptable levels.
Areva - now renamed Orano, and a key partner in the ISP CISF proposal targeted at WCS, TX, just 40 miles or so from Holtec's CISF - at its home base in France, experienced just such a plague or epidemic of externally contaminated shipments. A full 25% to 33% of Arevas irradiated nuclear fuel shipments, into its La Hague reprocessing facility, were externally contaminated, for years on end, above permissible levels. This amounted to many hundreds of individual shipments, contaminated above permissible levels, over the course of several years.
On average, the shipments were giving off radiation dose rates 500 times the permissible level; in one instance, a shipment was emitting radiation 3,300 times the acceptable level.
Environmental watchdogs and journalists revealed this contaminated shipment scandal. See the WISE-Paris write up, Transport Special - Plutonium Investigation n°6/7, posted at http://www.wise-paris.org/ under Bulletins.
But such externally contaminated shipments have happened in the U.S., as well.
Halstead documented this in a report prepared for the Nevada State Agency for Nuclear Projects in 1996. It is entitled Reported Incidents Involving Spent Nuclear Fuel Shipments, 1949 to Present. 49 surface contamination incidents are documented. This report is posted online at:
http://www.state.nv.us/nucwaste/trans/nucinc01.htm.
Here is the full text of that report:
Reported Incidents Involving Spent Nuclear Fuel Shipments 1949 to Present May 6, 1996 There have been 72 reported incidents involving spent nuclear fuel shipments from 1949 to present.
From 1949 to 1970 14 incidents were reported in a series of U.S. Atomic Energy Commission reports. They were either traffic accidents with no releases or nontraffic accident events with minor leaks suspected from the casks which resulted in small amounts of observed contamination.
From 1971 to present, 58 incidents have been reported in the Radioactive Material Incident Report database operated by Sandia National Laboratories. 49 of the 58 incidents involve minor surface contamination.
The 72 incidents can be characterized as follows:
4 incidents of accidental radioactive material contamination beyond the vehicle 4 incidents of accidental radioactive material contamination confined to the vehicle 13 incidents of traffic accidents, resulting in no release or contamination 49 incidents of accidental surface contamination
2 other incidents were mentioned in papers but descriptions are not available.
Eight incidents of radioactive material contamination (between 1960-1984) involved leaks of water, liquid, or (reported as) coolant/moderator from casks which were discovered during shipping. Description of the events and equipment are insufficient to evaluate the failure mechanisms or sources of contamination. However, the abbreviated information provided seems to indicate contributing factors may include the absence of regulations for design and use of transport casks, inadequate procedures, or not following the procedures. Some of the earlier incidents occur-red prior to the establishment of formal transportation regulations (1.966). (See attached incident reports.)
[Following] is a table describing each of the 72 incidents in more detail.
Reported Incidents Involving Spent Nuclear Fuel Shipments 1949 to Present (72 incidents by type)
Date Mode Incident Description Radioactive material contamination beyond the vehicle (4 of 72 incidents):
6/2/60 Rail Leak from cask, small areas at three rail yards contaminated, no runoff or aerial dispersion.
8/21/62 Truck Cask leakage, trailer and small portion of road contaminated.
11/11/64 Truck Cask leakage-, trailer, packages, and terminal contaminated.
1/27/84 Truck Slow drip from bottom front end of empty cask while stored in transportation terminal Radioactive material contamination confined to vehicle (4 of 72 incidents):
11/20/60 Truck Small leak from cask onto trailer floor, result, of shifting cask, contamination confined to vehicle.
9/22/61 Truck Leak from cask onto trailer floor, result of shifting, contamination confined to vehicle.
12/10/63 Rail Cask leakage, cask contaminated, contamination confined to trailer.
7/4/76 Truck Pinhole leak of, reported as, coolant/moderator on outside jacket of cask.
Shipment continued without risk to public.
Transportation accident. no release or contamination (13 of 72 incidents):
12/1/56 Truck Slid off icy road and overturned, 2 casks, I fell off trailer, no damage, no release.
1/29/57 Rail Uncoupling, damage from debris, no release.
4/15/60 Truck Trailer unhitched from tractor at 5 mph, no release.
11/15/60 Truck Truck jackknifed, struck station wagon, no release.
12/7/60 Rail Engine backed into cask car ' on siding, no release.
7/14/61 Rail Minor derailment at 10-12 mph, no release.
12/8/71 Truck Truck left 'road and cask thrown off, no release.
3/29/74 Rail Derailed tank car struck cask car in yard, empty cask, no release.
2/9/78 Truck Trailer buckled from weight, no release.
8/13/78 Truck Empty cask broke through trailer bed, no release.
12/9/83 Truck Tractor separated from intermediate set of axles, remained connected to trailer, no release.
3/24/87 Rail Train struck automobile at rail crossing, no release.'
1/9/88 Rail One set of rail car wheels derailed when switching tracks, empty cask, no release.
Surface contamination (49 of 72 incidents):
1/24/74 Truck Surface contamination on shipping pallet.
2/26/74 Truck Surface contamination on pallet and truck, empty cask.
4/29/74 Truck Surface contamination on pallet.
12/11/74 Truck Surface contamination on pallet.
12/23/74 Truck Surface contamination on pallet.
1/13/75 Truck Surface contamination on cask.
2/27/77 Truck Surface contamination on lifting yoke, empty cask.
4/13/77 Truck Surface contamination on trailer, empty cask.
5/3/77 Truck Surface contamination on empty cask.
5/12/77 Truck Surface contamination on empty cask.
5/16/77 Truck Surface contamination caused by small crack in impact limiter.
7/26/77 Truck Surface contamination on empty cask.
8/3/77 Truck Surface contamination.
8/23/77 Truck Surface contamination on cask.
2/16/78 Truck Surface contamination caused by open drain valve, empty cask.
2/27/78 Truck Surface contamination on empty cask.
5/16/78 Truck Surface contamination on empty cask.
7/24/78 Truck Surface contamination on empty cask.
7/29178 Truck Surface contamination on cask.
8/1/78 Truck Surface contamination on cask.
8/7/78 Truck Surface contamination on cask.
11/27/78 Rail Surface contamination on empty cask, yoke, and rail car caused by defective valve or closure.
3/28/79 Truck Surface contamination on empty cask and trailer.
4/2/79 Truck Surface contamination on cask.
4/2/79 Truck Surface contamination on empty cask.
4/3/79 Truck Surface contamination on tire chains, hold-down chains, and tighteners caused
by loading or unloading cask from trailer.
4/4/79 Truck Surface contamination on empty cask.
4/5/79 Truck Surface contamination on trailer, empty cask.
7/23/80 Truck Surface contamination on empty cask 8/25/80 Truck Surface contamination on cask.
2/2/81 Truck Surface contamination on empty cask and trailer 5/30/81 Truck Surface contamination on cask and trailer.
5/31/81 Truck Surface contamination on empty cask.
6/2/81 Truck Surface contamination on cask. Third consecutive instance of surface contamination, NRC suspends further shipments.
8/25/83 Truck Surface contamination on. empty cask.
9/30/83 Truck Surface contamination on empty cask.
10/21/83 Truck Surface contamination on empty cask.
1/7/84 Truck Surface contamination on empty cask.
1/25/84 Truck Surface contamination on empty cask.
2/24/84 Truck Surface contamination on cask.
1/11/85 Truck Surface contamination on trailer, empty cask.
2/3/85 Truck Surface contamination on cask.
7/8/85 Truck Surface contamination on empty cask.
2/28/86 Truck Surface contamination on empty cask.
7/29/86 Truck Surface contamination on cask.
7/29/86 Truck Surface contamination on empty cask and trailer 8/19/86 Truck Surface contamination on cask.
10115191 Truck Surface contamination on empty cask.
8/14/92 Truck Surface contamination on cask.
Unknown (2 of 72):
1965-1967 One incident, details not available.
1968-1970 One incident, details not available.
DEFINITIONS FOR RELEASE AND CONTAMINATION AS USED IN TRANSPORT ACCIDENT OR EVENT REPORTS RELEASE:
An official definition for release from a cask is not found in NRC's 10 CFR 7 1 (i.e., the Definitions section 71.4). However, an NRC definition of release as it pertains to transportation can be inferred from 10 CFR 71 as follows:
[10 CFR 71.4, Definitions] "Containment System means the components of a packaging intended to retain the radioactive material during transport."
[10 CFR 71.5 1, Additional requirements for Type B packages.] Paragraph (a)(1) prohibits loss or dispersal of radioactive contents for Normal Condition of Transport. Paragraph (a)(2) restricts escape of krypton or other radioactive materials for Hypothetical Accident Conditions. Finally, the word release is used in paragraph (b) which states: "Compliance,with the permitted activity release limits of paragraph (a) of this section must not depend upon filters or upon a mechanical cooling system."
From the above 10 CFR 71 material we can develop a definition that is consistent with NRC's rules and regulations. Release means loss, dispersal, or escape of radioactive material from the package's containment system.
CONTAMINATION:
[10 CFR 71.87(l)(1) and (1)(2), Routine determinations.] refer to. non-fixed (removable) radioactive contamination on external surfaces. These paragraphs prescribe specific limits for transport of radioactive materials. However, a formal definition is not provided.
Although the NRC's regulations do not provide a definition for contamination in 10 CFR 7 1, a definition is provided in NUREG-0770 (U.S. Nuclear Regulatory Commission, Glossary of Terms Nuclear Power and radiation, NUREG-0770,Washington, DC 20555, June 1981).
Contamination: "The deposition of unwanted radioactive material on the surface of structures, areas, objects, or personnel."
March 6,1996 Please address your woefully inadequate "hard look" under NEPA, re: this health-and environmentally-significant subject matter above. Thank you.
Sincerely, Kevin Kamps Radioactive Waste Specialist Beyond Nuclear 7304 Carroll Avenue, #182 Takoma Park, Maryland 20912 Cell: (240) 462-3216 kevin@beyondnuclear.org www.beyondnuclear.org Beyond Nuclear aims to educate and activate the public about the connections between nuclear
power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.
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